A tax resident of Singapore earned around ₹1.35 crore from selling Indian mutual funds but was initially served a tax notice in India after the income tax department rejected her exempt status. She invoked Article 13 of the India-Singapore Double Taxation Avoidance Agreement (DTAA), arguing that capital gains should be taxed only in her country of residence. The Income Tax Appellate Tribunal (ITAT) Mumbai upheld this interpretation, ruling in her favour because mutual fund units are not treated as shares under the treaty.